Finding Text
2023-008 – Procurement, Above Simple Acquisition (Significant Deficiency in Internal Controls
over Compliance)
Federal Program Information
Federal Award Title and ALN: Research & Development Cluster, 84.031
Federal Awarding Agency: U.S. Department of Education
Federal Award ID Number: P031S210288, P031C200002
Federal Award Year: 2023
Condition: During our review of procurement testing, the College did not get Board approval per
policy on a purchase over the threshold.
Criteria: Per 2 CFR 200.303(a), the non-federal entity must establish and maintain effective internal
control over the Federal award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award. These internal controls should be in compliance with guidance in
“Standards for Internal Control in the Federal Government” issued by the Comptroller General of
the United States or the “Internal Control Integrated Framework”, issued by the Committee of
Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR 200.318(i), non-federal entities must retain documentation sufficient to detail the history
of procurement decisions.
Cause: The College did not get Board approval for purchases above simple acquisition.
Effect: The College may unintentionally charge expenses to the program that do not qualify and in
turn lead to questioned costs and/or repayment of funds to the grantor agency.
Questioned Costs: None
Auditor recommendation: We recommend the College strengthen controls to ensure purchasing
policies and procedures are being followed and train staff in the purchasing department to comply
with all relevant federal procurement requirements.